Kepner-Tregoe Privacy Notice
Effective starting: May 25, 2018
Kepner-Tregoe, Inc, its subsidiaries and affiliates, take seriously our responsibilities to look after your data and we are committed to protecting your privacy. We collect and use your personal data when you or your organization interact with us. We have described how we collect, store and use your data in this Privacy Notice, along with the steps you can take to update and control what we do with your data. Throughout this notice the use of the terms “KT”, “we”, “us” and “our” refer to Kepner-Tregoe, Inc., its subsidiaries and affiliates. Also, as we have multiple websites, any reference to “Website” includes any Kepner-Tregoe website property.
When we talk about data and personal data in this Privacy Notice, we mean personal data which identify you or which could be used to identify you such as your name and business contact details such as your email address, company name, and job title. It may also include information about how you use our Websites, products, and services.
What you need to know
1) Who is responsible for your data
Kepner-Tregoe, Inc. is responsible for your data. Our registered address is 116 Village Blvd., Suite 300, Princeton, NJ 08540. We are registered as a company in Delaware, USA. We are the data controller of the data which we collect from you, and as such we control the ways your personal data are collected and the purposes for which your personal data are used.
2) Personal data we collect about you
We collect information about you when you provide it to us, when you or your company use our services or when other sources provide it to us. We may also obtain information from public sources, to make an initial contact with a relevant individual at a client or other company. Most of the personal data we collect, and use relates to individual employees of our clients and other companies with which we have an existing business relationship, along with other companies with whom we want to develop a business relationship.
For clients with whom we have a business relationship and potential clients, we may collect personal data such as your name and business contact details, publicly available information if relevant for business purposes, your responses to targeted e-mails (including web activity following links from our e-mails), Website activity of registered users of our Websites, and other business information included by Kepner-Tregoe professionals based on their professional interactions with you.
For existing clients, payment and billing information is collected when facilitating purchasing or payment of services.
When you register for or participate in a workshop (KT or company run workshop or Leadership Development Program) we collect the same information as for clients described above as well as, workshops or programs you have attended. For Leadership Development Programs we’ll also collect information related to your certifications.
For candidates, if you apply through our Websites, we collect personal data that you submit and use it for our recruiting process. We collect and use the same information as for potential clients described above. Additional information about personal data collected and how it will be used by KT will be provided as part of the recruiting process.
Sensitive personal data
Certain kinds of personal data, such as your personal identity number, your financial account information, your racial or ethnic origin, your political opinions, your religious philosophical, or other similar beliefs, your membership of a trade union or profession or trade associations, your physical or mental health, your sexual life, biometric or genetic data, or alleged commission or conviction of criminal offences, are special categories of personal data which by law require additional protection and in some cases require explicit consent. We try to limit the circumstances in which we collect sensitive personal data of this kind. When we do seek collection of this data, we will do this in accordance with local data privacy law requirements. By providing solicited or unsolicited sensitive personal data, you explicitly agree that we may collect it and use it to provide services to you.
3) How we use your personal data
We can only use your personal data if we have a proper reason for doing so. According to the law, we can only use your data for one or more of these reasons:
To fulfil a contract, we have with you or your organization
If we have a legal duty to use your data for a particular reason
When you consent to it
When it is in our legitimate interest.
Legitimate interest includes our business or commercial reasons for using your data.
Countries take a different approach to the use by companies of legitimate interests as a reason for processing personal data. We are aware of those different approaches in the countries in which we operate, and we take that into account and respect those differences when we process your personal data.
We send commercial email to individuals at our clients or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. You can exercise your right to prevent our marketing communications by checking certain boxes on the forms we use to collect your personal data, or by utilizing unsubscribe (opt-out) in e-mails we send you or email us at email@example.com.
We use information when you voluntarily submit it to us for information requests, event registrations, session registrations, downloading white papers, case studies, viewing video content or participation in an online survey or contest. All of these are voluntary and, therefore, you have the option to participate and submit the information or not. When we collect this type of information, we will notify you as to why we are asking for the information and for how it will be used.
We may use your contact details to send information about the services you or your company are contracted to, and to provide the contracted services. You cannot opt-out of receiving transactional emails related to your account or use of our services.
We maintain records of services we have provided to you including course attendance and KT certifications. You cannot opt-out of receiving emails related to your course attendance or certifications.
Job applicant information is used to evaluate and communicate applicants as candidates for open positions at KT, and if applicable, in our hiring process.
4) How we use your data to personalize the service we offer you
When you access our site, your Internet address is automatically collected and is placed in our Internet access logs to analyze trends, administer the site, track user movement and gather aggregate information. “Aggregate information” is information that describes the habits, usage patterns and/or demographics of users as a group but does not describe or reveal the identity of any user. Your Internet address is not linked to any personally identifiable information.
5) Marketing: How to manage the marketing messages you receive
We may send you marketing communications by email if you have indicated that you are happy to receive such emails or if you have done business with us and you haven’t told us that you no longer wish to receive marketing emails. Our marketing communications include information about our new and existing products and services along with educational material we think you might like or we think might be useful.
If you have previously opted-in to receiving emails from us, use the Preference Center to tell us specifically what you are interested in hearing about, or to opt out of receiving marketing emails from us. We are still finalizing our Preference Center which will be available shortly. You can update your preferences at any time. You can also opt out of receiving marketing emails by clicking on the unsubscribe link which we include in all our marketing emails or email us at firstname.lastname@example.org. You may also contact us by telephone or by postal mail to request an opt-out.
Please note that if you tell us that you do not wish to receive marketing emails, you may still receive service emails which are necessary for us to perform any contract we have with you or your company.
6) How long we keep your data
We keep your data only for as long as we need it. How long we need data depends on what we are using it for, whether that is to provide services to you, for our own legitimate interests (mentioned above) or so that we can comply with the law.
We will actively review the information we hold and when there is no longer a client, legal or business need for us to hold it, we will either delete it securely or in some cases anonymize it.
7) How we protect your data
We protect your personal data against unauthorized access, unlawful use, accidental loss, corruption or destruction.
We use technical measures such as encryption and password protection to protect your data and the systems they are held in. Our primary system of record for client data is stored in our Client Relationship Management Database (CRM).
We host our Websites in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders.
We keep these security measures under review and refer to industry security standards to keep up to date with current best practice. While we strive to protect your personal or company information by encryption and other means, we cannot guarantee or warrant the security of the information you transmit to us, and if you choose to use our Website, you do so at your own risk. Please keep in mind that the information disclosed by you on our Website via a chat room, bulletin board or other similar submission, may be collected and used by other users of the Website.
8) Sharing your data
We will not sell individual information and will only share it with our advisors who will not use it for any secondary purposes. “Individual information” is information about a user that is presented in a form distinguishable from information relating to other users but not in a form that personally identifies any user or enables the recipient to communicate directly with any user. We may share aggregate and survey information, but this information is not linked to any personal information that can identify any individual person. However, you should be careful when including any personal information in any submission or as a part of any chat room discussion. This information may be readily available to other users and we cannot control their use of that information.
We use outside shipping companies to ship orders, and credit card processing companies to bill you for products and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes. We may partner with another party to provide specific services. If you request these services, we will share your name or other contact information that is necessary for the third party to provide the services. These third parties are not permitted to use the personally identifiable information except for the purposes of providing the requested services.
We may disclose information about you or your company if we have a good faith belief that we are required to do so by law or legal process, to respond to claims, or to protect our rights, property or safety or those of others.
9) Sending data internationally
Our CRM primarily stores personal information described in this Privacy Notice in the United States. To facilitate our global operations, we may transfer or access such information from around the world, including from other countries in which we have operations who we use to deliver services to you or to comply with a legal duty. A list of our global offices is available here. Irrespective of which country you reside in or supply information from, you authorize us to use your information in the United States and any other country where we operate. If we do transfer data outside the United States, this Privacy Notice applies. If you do not consent to the use of your personal information as described in this privacy notice, please do not use our Websites or provide your personal information. If you’ve previously provided personal information and would like it to be removed or changed, please refer to the “Your rights” section below.
10) Your rights
You are entitled to see copies of all personal data held by us and to amend, correct or delete such data. You can also limit, restrict or object to the processing of your data. You can email us at email@example.com.
If you gave us your consent to use your data, e.g. so that we can send you marketing emails, you can withdraw your consent. Information about how to stop receiving marketing communications is set out above under the heading ‘Marketing: How to manage the marketing messages you receive’. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your data before you withdrew your consent.
To raise any objections or to exercise any of your rights on the use of your personal data, you can email us at firstname.lastname@example.org.
When you get in touch, we will come back to you as soon as possible and where possible within one month. If your request is more complicated, it may take a little longer to come back to you, but we will come back to you within two months of your request. There is no charge for most requests, but if you ask us to provide a significant amount of data for example we may ask you to pay a reasonable admin fee. We may also ask you to verify your identity before we provide any information to you.
11) Policy towards children
Our products and services are not directed to persons under the age of 16, and we do not knowingly collect personal information from children under the age of 16. If you become aware that your child has provided us with personal information without your consent, please contact us at email@example.com.
12) Changes to privacy notice
We may revise our privacy notice from time to time. The most current version will be posted on our Websites, so you are always aware of what information we collect, how we use it, and under what circumstances. If at any point we intend to use any personally identifiable information in a manner different from what was stated at the time it was collected, we will notify you by email (if you provided your email address) if your information is affected. You will have a choice as to whether we use the information in that way.
14) Contact Us